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Income Taxes (Tables)
12 Months Ended
Dec. 31, 2012
Income Taxes [Line Items]  
Schedule of Income Tax Reconciliation
The following table reconciles REIT GAAP net income (loss) to taxable income (in thousands):
 
 
Year Ended December 31,
 
 
2012
 
2011
 
2010
GAAP net loss from REIT operations
 
$
(125,088
)
 
$
(127,709
)
 
$
(172,495
)
Book/tax differences, net:
 
 
 
 
 
 
Depreciation and amortization(a) 
 
2,084

 
6,183

 
(17,645
)
Noncontrolling interests
 
4,112

 
4,149

 
(882
)
Equity in loss from unconsolidated entities
 

 

 
(35,386
)
Tax gain (loss) on dispositions in excess of book
 
(30,747
)
 
(30,502
)
 
34,729

Impairment loss not deductible for tax
 
1,335

 
12,303

 
156,773

Conversion costs
 
31,197

 

 

Tax adjustment to lease revenue(b)
 

 

 
(35,634
)
Other
 
(9,226
)
 
(1,974
)
 
(6,452
)
Tax loss(c)
 
$
(126,333
)
 
$
(137,550
)
 
$
(76,992
)

(a)
Book/tax differences in depreciation and amortization principally result from differences in depreciable lives and accelerated depreciation methods.
(b)
For tax purposes, we recorded a reduction in intercompany rent between our REIT entities and TRS entities.
(c)
The dividend distribution requirement is 90% of any taxable income.
Schedule of Deferred Tax Asset
Our TRS had a deferred tax asset, on which we had a 100% valuation allowance, primarily comprised of the following (in thousands):

 
 
December 31,
 
 
2012
 
2011
Accumulated net operating losses of our TRS
 
$
124,318

 
$
129,455

Tax property basis in excess of book
 
869

 
929

Accrued employee benefits not deductible for tax
 
2,291

 
760

Management fee recognition
 
932

 
1,415

Foreign exchange
 
4,905

 

Other
 
914

 
970

Gross deferred tax asset
 
134,229

 
133,529

Valuation allowance
 
(134,229
)
 
(133,529
)
Deferred tax asset after valuation allowance
 
$

 
$

Schedule of Characterization of Cash Dividends Distrubuted
For income tax purposes, dividends paid consist of ordinary income, capital gains, return of capital or a combination thereof. Dividends paid per share were characterized as follows (there were no distributions in 2010):
 
 
 
 
 
 
 
2012
 
2011
 
2010
 
Amount
 
%
 
Amount
 
%
 
Amount
 
%
Preferred Stock – Series A
 
 
 
 
 
 
 
 
 
 
 
Dividend income
$

 
 
$

 
 
$

 
Return of capital
5.3625

(b) 
100.00
 
1.95

(a) 
100.00
 

 
 
5.3625

 
100.00
 
$
1.95

 
100.00
 
$

 
Preferred Stock – Series C
 
 
 
 
 
 
 
 
 
 
 
Dividend income
$

 
 
$

 
 
$

 
Return of capital
5.50

(b) 
100.00
 
2.00

(a) 
100.00
 

 
 
$
5.50

 
100.00
 
$
2.00

 
100.00
 
$

 

(a)
Fourth quarter 2010 preferred distributions were paid January 31, 2011, and were treated as 2011 distributions for tax purposes.
(b) Fourth quarter 2011 preferred distributions were paid January 31, 2012, and were treated as 2012 distributions for tax purposes.
Taxable REIT Subsidiaries [Member]
 
Income Taxes [Line Items]  
Schedule of Income Tax Reconciliation
The following table reconciles our TRS’s GAAP net income (loss) to taxable income (loss) (in thousands):
 
 
Year Ended December 31,
 
 
2012
 
2011
 
2010
GAAP consolidated net loss attributable to FelCor LP
 
$
(128,849
)
 
$
(130,543
)
 
$
(223,922
)
Loss allocated to FelCor LP unitholders
 
842

 
689

 
881

GAAP consolidated net loss attributable to FelCor
 
(128,007
)
 
(129,854
)
 
(223,041
)
GAAP net loss from REIT operations
 
125,088

 
127,709

 
172,495

GAAP net loss of taxable subsidiaries
 
(2,919
)
 
(2,145
)
 
(50,546
)
Impairment loss not deductible for tax
 

 
946

 
8,852

Tax gain (loss) in excess of book gains on sale of hotels
 
(407
)
 
(7,841
)
 

Depreciation and amortization(a) 
 
404

 
1,389

 
(106
)
Employee benefits not deductible for tax
 
363

 
(1,578
)
 
3,534

Management fee recognition
 
(1,715
)
 
(1,717
)
 
916

Tax adjustment to lease expense(b) 
 

 

 
40,572

Foreign exchange
 
12,907

 

 

Other book/tax differences
 
4,884

 
(552
)
 
5,251

Tax income (loss) of taxable subsidiaries before utilization of net operating losses
 
13,517

 
(11,498
)
 
8,473

Utilization of net operating loss
 
(13,517
)
 

 
(8,473
)
Net tax loss of taxable subsidiaries
 

 
$
(11,498
)
 
$


(a)
The changes in book/tax differences in depreciation and amortization principally result from book and tax basis differences, differences in depreciable lives and accelerated depreciation methods.
(b)
In 2010, we recorded a reduction in intercompany rent between our REIT entities and TRS entities for tax purposes.